Toolkit of Promising Practices for Financing Integrated Care in the California Safety Net

1. Toolkit of Promising Practices for Financing Integrated Care in the California Safety Net Dale Jarvis, CPAdale@djconsult.net

2. Quick Reminders About Your Audio • Make sure you phone is on mute except when you want to talk • Make sure this button is clicked if you’re calling in by telephone • Make sure this button is clicked if you’re using the computer’s microphone and speakers 2

3. Mechanics of Q&A • You can raise your hand and I will unmute you • You can type a question into the question dialog box

4. Context for the Toolkit – The New Healthcare Ecosystem

5. For More Information…

6. Today’s Agenda • Introduction to the Toolkit • Brief History Lesson • Eight Steps to Integrated Care • The Top Ten Barriers • Tomorrow’s Payment Models • Epilogue: The Customization of the Medical Home

7. Be thinking bout… • What is one question you’d like answered today? • What is one problem you’d like solved today?

8. Introduction to the Toolkit

9. Why this Toolkit? To figure out how to ensure that California projects doing this cutting edge work don’t go bankrupt in the process?

10. Two Audiences… • Provider Organizations (MH, SU, Health) • How do you navigate the existing funding maze? • Payors/Managers (Counties, MISPs/ CMSPs, etc.) • What can you do to create a more supportive payment and regulatory system (today and tomorrow)?

11. Across the Continuum of Those Working on Integration… • Are you contemplating an integration project? • Are you deep into planning the project? • Are you well underway?

12. WarningRead Before Proceeding! • “By all rights, every project should have failed. We have identified ten major funding obstacles and chronicled countless stories about cultural differences, political hurdles, turf battles, personality clashes, and more.”

13. Quick Guide

14. Brief History Lesson

15. A Tale of 3 Siblings Why this toolkit? It’s really a story of 3 “safety net” siblings separated when children- the Health (FQHC), MH and SU (ADP) Systems

16. Community Health Centers

17. CMHCs: De-Federalized Program Managed by the States Sister of CHCs in the 1960s and 1970s Part of the Shift and Shaft strategy that began in 1981 Leaving success or failure up to each state’s leadership and funding levels and the ability of local CBHOs to succeed (or not) in a highly regulatedand underfundedenvironment.

18. Meanwhile… • The dysfunction of the rest of the American Healthcare System has been creating a huge sucking sound in the American Economy (next chapter) • And funding for the safety net has taken a back seat to centers of power: insurance companies, pharmaceutical companies, hospitals, specialty physicians, etc… Sources: HRSA, NASMHPD, SAMHSA, Kaiser, Commonwealth Fund

19. What’s Next: The future of Health and Behavioral Healthcare Organizations in America • The head is being reconnected to the body • Your presence here today signifies that you are on the leading (and hopefully not bleeding) edge of this change process

20. Another View of the Ecosystem

21. Questions? dale@djconsult.net • What is one question you’d like answered today? • What is one problem you’d like solved today?

22. Opening the Toolkit How to Get Paid Today for Integrated Care

23. Step 1: Engage Top Leadership and Identify a Project Champion • The senior leadership of the PC and BH systems have made a strong commitment to ensuring the success of the project and follows through. • Each project has a dedicated champion with optimism, tenacity, attention to detail, and belief that the project can make a difference. Leadership Engagement

24. Step 2: Organize a Planning Workgroup and Prepare a High Level Project Timeline • Healthcare is quickly moving from an individual sport to a team sport. • Thus, the importance of a multidisciplinary workgroup involving local primary care, mental health, and substance use integration partners.

25. Step 3: Design the Clinical Model

26. Step 4: Identify and Address Your Funding Barriers • Case in Point: The Walls of Dubrovnik, Croatia were considered to be amongst the great fortification systems of the Middle Ages, as they were never breached by a hostile army. If you are facing similar financing barriers, find a new castle to storm and move on to other ways to finance your integration project.

27. This can be done by sketching out the most frequent clinical workflows in your integration project and noting how each step in the flow will be funded – or not.

28. Step 5: Design a Detailed Implementation Plan Many successful projects organize their implementation into multiple phases, as opposed to a “big bang” approach that attempts to bring the entire integration plan online at once.

29. Step 6: Prepare a Detailed Integration Budget How many people? How much service? Staff demand? Operating Budget? Other Costs? Revenue Projections? In Balance? If No, change design.

30. Step 6: Prepare a Detailed Integration Budget • Budget for services in the primary care clinic • Budget for services in the behavioral health center

31. Step 7: Revise your Infrastructure and Obtain Necessary Approvals (The devil is in the details) • Does the Health Center require a change in Scope of Project due to changes in services, providers and places where those providers provide services? • Who will own the charts and how will documentation be shared? • Will a shared patient registry be implemented that tracks key demographic, utilization, and clinical information? • Are we currently capturing the appropriate data in the primary care clinic and behavioral health center to properly bill and be paid for services?

32. Don’t let your project get derailed by the need for a sink!

33. Step 8: Go Live; Monitor and Adjust, As Needed • The future is in Rapid Cycle Improvement, not plastics…

34. Questions? • What is one question you’d like answered today? • What is one problem you’d like solved today?

35. Toolkit of Promising Practices for Financing Integrated Care in the California Safety Net, Part 2 Dale Jarvis, CPAdale@djconsult.net

36. Quick Reminders About Your Audio • Make sure this button is clicked if you’re calling in by telephone • Make sure this button is clicked if you’re using the computer’s microphone and speakers 36

37. Mechanics of Q&A • You can raise your hand and I will unmute you • You can type a question into the question dialog box

38. Today’s Agenda • Introduction to the Toolkit • Brief History Lesson • Eight Steps to Integrated Care • The Top Ten Barriers • Tomorrow’s Payment Models • Epilogue: The Customization of the Medical Home

39. The “Top Ten” Barriers to Getting Paid for Integrated Care

40. Top 10 Barriers • Health Center Billing of MH/SU Services • Limitations on Who Can Bill for Services • Psychiatric Consultation to Primary Care Provider/Care Manager • Lack of Codes for Non Face-to-Face Psychiatric Consultation, Care Management, and SBIRT • Barriers to Team-Based Care • Mental Health Diagnosis as Primary in Primary Care • Inability to Bill for Telephone, Telemedicine, and Email-Based Services • Care Provided Outside the Four Walls • Same Day Billing Restriction • Poor Reimbursement for HBA Codes

41. The moral of this story? • Working together using the partnership model of bidirectional care is almost always the best way to succeed at managing complex cases and getting paid in the current environment.

42. Leveraging Who Works Where to Get Paid • Strategic employment of behavioral health clinicians – in the Health Center or in the Behavioral Health Center – can make the difference in whether you get paid or not. • Although the conventional wisdom is to try and bill through the Health Center to access the PPS rate, there are many instances in which behavioral health clinicians working for the behavioral health center stationed at the Health Center is the best solution.

43. Barrier 1: Health Center Billing of Mental Health and Substance Use Services • Integration at an FQHC almost always requires a “Scope of Project Change” • Change in Services, Sites, and/or Providers • Sound simple, but… • California has a lengthy and complex process • Opens a potential Pandora’s Box of rate review

44. Barrier 2: Limitations on Who Can Bill for Services • HRSA regulations limit which behavioral health providers can bill for services to: • Psychiatrists • Psychologists • psychiatric nurse practitioners, and • licensed clinical social workers • “If grant funding is available and you are faced with a shortage of LCSWs, Elizabeth Morrison at Golden Valley Health Centers suggests hiring CSWs who are working toward their license, funded through grant dollars, and shift their funding to billable services when they become licensed. This has the added benefit of helping address workforce shortage issues.” • Latest Question: Can providers who can’t bill work under the license of a billable provider, providing “incident to” services?

45. Barrier 3: Psychiatric Consultation to Primary Care Provider or Care Manager • Louise Rogers pointed out that in California, Medi-Cal mental health rules in fact allow for these types of phone calls and pay by the minute. This solution, however, requires that the consult is coming from someone outside the Health Center. • The lesson then is twofold – there is a solution, and the solution is to be careful how fully you have integrated your system. • If the consult is coming from someone within the Health Center, it cannot be billed, whereas if it is coming from an outside specialist, even one based in primary care, it can be billed.

46. Barrier 4: Lack of Codes for Non Face-to-Face Psychiatric Consultation, Care Management, and SBIRT • 3 CPT Manual Sections • Evaluation and Management (99201-99340) • Psychiatry (90801-90899) • Health Behavioral Assessment (96150-96155) • Not all “turned on” by payors (e.g. SBIRT 99211, 99408 and 99409) • No CPT codes for non-face-to-face services • CA Health Centers cannot bill for group

47. Barrier 5: Barriers to Team-Based CareBarrier 9: Same Day Billing Restriction • Cannot bill multiple providers for the same visit or multiple visits on the same day in health centers • Solutions? • Adjust the PPS rate • Grant funding • Use clinicians working for the behavioral health center

48. Questions? • What is one question you’d like answered today? • What is one problem you’d like solved today? Q: If billing medi-cal is the requirement that the service provider be a licensed clinical social worker - can they be an MFT? - can they be interns? Q: If billlingmedi-cal does the assessment need to be as complicated as the 'specialty MH" which often Q: Will you be talking about setting reimbursement rates for both MH and FQHC? Q: Or are you aware of any specific implications related to Meaningful Use implementation.

49. How You Will Get Paid Tomorrow: New Healthcare Reform Payment Models 49

50. California is Soooo… Fee for Service Centric